The OECD's BEPS project mandated that transfer pricing outcomes under the arm's-length standard should be aligned with value creation. In the digital economy, new business models are challenging transfer pricing practitioners on how best to apply the value creation approach. In a two-part series...

Tax Management International Journal, 50.2 (Feb. 2021): 90-97. Reproduced with permission from Bloomberg Tax (Feb 5, 2021). Copyright 2021 The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com.Abstract: The Amount B proposal in the Pillar One Blueprint released by...

The growth of technological capability and industrial productivity in developing countries depends critically on the effectiveness of investments in learning and assimilating the new technologies. Empirical studies of investments in absorptive activity, e.g., R&D, training and technical...